Justia Civil Rights Opinion Summaries

A jury convicted Defendant of possession with intent to distribute methamphetamine and conspiracy to distribute methamphetamine in violation of 21 U.S.C. Sections  841(a)(1) and 846. He appealed the district court’s denials of his motion to suppress evidence, his motion to strike a juror for cause, and his motion to admit a portion of a video recording.   The Eighth Circuit affirmed Defendant’s convictions. Defendant argued that the seizure and detention of the lockboxes was unreasonable under United States v. Place, 462 U.S. 696 (1983). But “Place had nothing to do with the automobile exception and is inapposite.” See Acevedo, 500 U.S. at 578 (noting that the Supreme Court has consistently “explained that automobile searches differ from other searches” and has denied the applicability of cases that “do not concern automobiles or the automobile exception” to cases involving the automobile exception). Therefore, the district court did not err in denying Defendant’s motion to suppress. Further, the court wrote there was no abuse of discretion because the juror stated that she could remain fair and would listen to the detective’s testimony before deciding if she believed it. Finally, Defendant claimed that the “partial recording and the Government’s characterization of it . . . gave a misleading and unfair understanding of the meaning of Defendant’s statement to the jury.” But he offers no explanation of how the recording was misleading. View "United States v. Shaun Farrington" on Justia Law

After a thirteen-year-old victim of human trafficking performed at a City of Miami Beach (“the City”) fully nude strip club, Club Madonna, Inc. (“the Club”), the City came down hard on the Club. It enacted two closely intertwined ordinances (collectively, “the Ordinance”) that required all nude strip clubs to follow a record-keeping and identification-checking regime in order to ensure that each individual performer is at least eighteen years old.   The district court ruled for the City at summary judgment on the Club’s first two claims, ruled for the Club on its federal preemption claim at summary judgment, and ruled for the City on the Club’s state law preemption claim at the motion-to-dismiss stage for failure to state a claim. The Club then appealed the court’s rulings and the City cross-appealed the district court’s ruling on the Club’s federal preemption claim.   The Eleventh Circuit affirmed on all counts. First, although the Ordinance implicates the First Amendment because it singles out an industry that engages in expressive activity for special regulation, it satisfies intermediate scrutiny. Second, the Ordinance’s warrantless-search provision does not violate the Fourth Amendment because the adult entertainment industry is a closely regulated industry for Fourth Amendment purposes, and the warrantless-search provision satisfies the administrative-search exception because it can be narrowly read to avoid Fourth Amendment concerns. Third, the Ordinance’s employment-verification requirement is preempted by federal immigration law. And finally, the Club’s state law conflict preemption claim fails because there is no Florida law that cabins the City’s ability to levy fines against the Club for violating the Ordinance’s requirements. View "Club Madonna Inc. v. City of Miami Beach" on Justia Law

Plaintiff appealed from a district court’s order awarding him attorney’s fees under 42 U.S.C. Section 1988 in an amount substantially less than he sought. After Plaintiff prevailed against the City of New York on the merits of his due process claim under 42 U.S.C. Section 1983, the district court, adopting the report and recommendation of the magistrate judge, lowered the attorney’s claimed hourly rate, excluded time spent on a related concurrent administrative proceeding, struck certain billing entries and imposed a 40% across-the-board reduction to the fee request.   Plaintiff challenged primarily the across-the-board reduction and the exclusion of time-related to the administrative proceeding. The Second Circuit vacated the district court’s order, explaining that while it identified no error in the district court’s decision to exclude all hours related to that proceeding, the court found that the 40% blanket reduction was not justified on the record. The court explained that it agrees with Plaintiff that the 40% overall reduction applied by the district court was not justified: the district court was able to (and in fact did) examine the block-billed entries for reasonableness, and Plaintiff’s counsel obtained a strongly favorable result for him overall, prevailing on claims that rested on the same core set of facts as did the claims that the court dismissed. However, the court identified no error in the district court’s decision to exclude from the fee calculation the hours that Plaintiff’s counsel devoted to defending him in the OATH proceeding because Plaintiff has not shown that this work was necessary to the result achieved in the federal court. View "Raja v. Burns" on Justia Law

Defendant was indicted for knowingly producing child pornography in violation of federal law. He moved to suppress evidence gathered from his electronic devices, arguing that the government’s search warrants lacked probable cause and therefore violated his Fourth Amendment rights. The district court denied the motion. Defendant then pleaded guilty but reserved the right to appeal the district court’s decision on his motion to suppress.   The Second Circuit affirmed the district court’s judgment explained that it disagrees with the district court that Defendant’s prior guilty plea to an earlier charge in Tennessee state court precludes him from challenging the search warrants in this case. But the court agreed that even assuming arguendo that the warrants are defective, the good-faith exception to the exclusionary rule applies.   The court explained that there was at least arguable probable cause for the Tennessee Warrants, therefore, the Detective acted based on an “‘objectively reasonable good-faith belief’ that [his] conduct [was] lawful.” The court further wrote that the affidavits at issue here are not so devoid of factual support because they detail allegations from State Victim 1’s mother that support the common-sense inference that her daughter told her that Defendant took nude photographs of her. View "United States v. Jones" on Justia Law

The Supreme Judicial Court reversed the decision of the trial court convicting Defendant of operating a motor vehicle while under the influence of alcohol (OUI) and negligent operation of a motor vehicle, holding that the trial court erred in denying Defendant's motion to suppress.Defendant moved to suppress the results of a blood alcohol content (BAC) analysis conducted by a crime lab after the police obtained and executed a search warrant for Defendant's blood, arguing that he did not consent to having his blood tested. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that, in a prosecution under 24(1)(a), where the Commonwealth wishes to have admitted BAC evidence arising from testing or analysis of a defendant's blood done "by or at the direction of" police, police must first obtain the defendant's consent to the "chemical test or analysis" of his blood that may result from such evidence, regardless of whomever first drew the blood. View "Commonwealth v. Moreau" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to suppress evidence obtained during a search that led to the State charging Defendant with possession of drugs and drug paraphernalia with the intent to distribute, holding that the district court properly denied the suppression motion.This appeal arose after police officers detained Defendant while he sat in a minivan in an alleyway. Defendant filed a motion to suppress the evidence obtained during the search, arguing that the seizure of the minivan violated his constitutional rights. The district court concluded that the detention was reasonable and justified under the public safety exception to the warrant requirement. The court of appeals affirmed. The Supreme Court affirmed, holding that the seizure of the minivan was reasonable under the Fourth Amendment and section 15 of the Kansas Constitution Bill of Rights. View "State v. Bates" on Justia Law

Plaintiffs are several parents suing on behalf of themselves and their children, whose requests for medical exemptions from the school immunization requirements were largely denied. They brought this action below against Defendants, the New York State Department of Health (the "Health Department"), Health Department officials, local school districts, and local school district officials (collectively, "Defendants"), alleging that the new regulations and the enforcement thereof violated their rights under the Due Process Clause of the Fourteenth Amendment and Section 504 of the Rehabilitation Act, 29 U.S.C. Section 794 (the "Rehabilitation Act"). The district court granted Defendants' motions to dismiss for failure to state a claim.   The Second Circuit affirmed the district court’s judgment. The court first concluded, as a procedural matter, that the district court properly applied the motion to dismiss standards. The court then concluded, as a substantive matter, that neither the new regulations nor the enforcement thereof violated the Due Process Clause or the Rehabilitation Act. The court explained that the new regulations do not implicate a fundamental right and that therefore strict scrutiny does not apply. The court further found that there is a reasonable relationship between the delegation of authority to school districts to review and approve medical exemption requests and protecting communities from serious diseases. Finally, the court concluded that Plaintiffs fail to plausibly allege that they were excluded from school "solely by reason of" their disabilities. View "Goe v. Zucker" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to withdraw his no contest pleas to six felony charges, holding that there was no error.After the district court accepted Defendant's no contest pleas, Defendant filed a motion to withdraw his pleas, claiming that he wanted to withdraw his pleas so that he could obtain a second opinion as to his sanity at the time of the charged offenses. The district court denied the motion to withdraw. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by overruling Defendant's motion to withdraw his pleas; and (2) the record was insufficient to review Defendant's claim of ineffective assistance of counsel on direct appeal. View "State v. Warner" on Justia Law

This appeal arises from an alleged sexual assault committed by a law enforcement officer while he was conducting a welfare check on Plaintiff at her home. The district court found that the officer was entitled to qualified immunity. The district court found that Plaintiff’s Fourth Amendment claim of excessive force failed because Plaintiff had not been seized, and that the Eighth Amendment claim failed because she was not a prisoner. Plaintiff appealed the dismissal of her claims under the Fourth Amendment and Fourteenth Amendment, as well as her claims against the County and Sheriff.   The Fifth Circuit affirmed the district court with respect to the dismissal of Plaintiff’s Fourth Amendment claim, reversed the order of the district court with respect to the dismissal of Plaintiff’s Fourteenth claim, and remanded. The court held that the Deputy’s alleged sexual abuse violated Plaintiff’s clearly established right to bodily integrity. Thus, the Deputy is not entitled to qualified immunity. The court explained it need not reach the claims against the County and the Sheriff. The court remanded those issues to the district court to address in the first instance. View "Tyson v. County of Sabine" on Justia Law

The Seventh Circuit affirmed the judgment of the district court dismissing for failure to state a claim this lawsuit raising claims under the Fourth Amendment and the Due Process Clause of the Fifth Amendment, holding that the judge properly dismissed the case in its entirety and with prejudice.In 2017, agents with the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) executed a search warrant at an Indiana facility owned by Paraklese Technologies, LLC, which makes and sells firearm accessories, and seized approximately $21,000 worth of inventory. In 2017, Paraklese and its owner sued ATF agents seeking damages from the search and seizure. The district court granted Defendants' motion to dismiss for failure to state a claim. The Seventh Circuit affirmed, holding that the district court did not err in dismissing the case. View "Fosnight v. Jones" on Justia Law